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Type of Publication: Guideline

Category: Sound Business and Financial Practices

Date: October 2010

No: E-19

Audiences: Banks / BHC / T&L

This Guideline outlines OSFI’s expectations with respect to an
institution’s internal capital adequacy assessment process as described
in Part 3 of the Basel II Framework. Footnote 1 It applies
to banks, bank holding companies and to federally regulated trust
and loan companies, collectively referred to as institutions.

OSFI’s supervisory review process evaluates the inherent risk
within each significant activity undertaken by an institution and
then evaluates the quality of the risk management applied to mitigate
these risks. OSFI’s assessment of an institution’s ICAAP supplements
its independent assessment of inherent risk and risk management,
and can result in fine-tuning of these assessments.

Statement of Regulatory Principles

Capital requirements specified in the CAR Guidelines A and A-1
are regulatory minimums that assume an institution has a portfolio
of risk exposures that is highly granular and widely diversified.
Because minimum regulatory capital requirements contain restrictive
or simplifying assumptions, an institution should not rely only
on compliance with regulatory minimums when conducting its own assessment
of the adequacy of its capital.

A thorough and comprehensive ICAAP is a vital component of a strong
risk management program. The ICAAP should produce a level of capital
adequate to support the nature and level of an institution’s risk.
Each federally-regulated deposit-taking institution is responsible
for developing and implementing its own ICAAP for the purpose of
setting internal capital targets and developing strategies for achieving
those internal targets that are consistent with its business plans,
risk profile and operating environment.

From OSFI’s perspective, ICAAPs provide additional information
that can aid in assessing inherent risk and may point to the need
for additional supervisory work as part of the normal course Supervisory
Review Process. While OSFI makes use of information gleaned from
an institution’s ICAAP to assess the quality of risk management,
OSFI does not approve an institution’s ICAAP.

Scope of the ICAAP

OSFI expects federally regulated deposit-taking institutions,
including Canadian subsidiaries of foreign banks, to put into place
an ICAAP that covers the consolidated operations from the top level
regulated entity in Canada. The consolidated approach means that
a formal ICAAP is not required at every legal entity below the Canadian
parent institution.

Although an ICAAP should cover the consolidated operations from
the top level regulated entity in Canada, OSFI expects an institution’s
capital planning to consider the risks of its foreign operations
and also the availability of capital and assets in Canada to protect
Canadian depositors.

Canadian subsidiaries of foreign banks may borrow from consolidated
group methodologies for assessing risk. However, a foreign bank
subsidiary’s ICAAP should reflect its own circumstances, and group-wide
data and methodologies should be appropriately modified to yield
internal capital targets and a capital plan that is relevant to
the foreign bank subsidiary.

Expectations for an Institution’s ICAAP

A rigorous ICAAP has six main components:

Board and senior management oversight

Sound capital assessment and planning

Comprehensive assessment of risks

Stress testing

Monitoring and reporting

Internal control review

While these fundamental features of ICAAP are broadly prescribed,
there is no single ‘correct’ approach, and one approach does not
fit all institutions. An institution’s ICAAP should be as simple
or complex as needed, and should reflect how the institution is
managed and organized in practice. It should not be established
solely to fulfill a regulatory requirement.

The extent of formalization and sophistication of ICAAPs will
differ, depending on the institution’s complexity, range of business
activities, risk profile, and operating environment.

I. Board and senior management oversight

The board of directors is responsible for overseeing, and senior
management is responsible for designing and implementing the institution’s
ICAAP. In order to perform an effective assessment of its capital
adequacy, an institution should have in place a sound risk management
process. Management should understand the nature and level of risk
taken by the institution and how this risk relates to adequate levels
of capital. Management should also ensure that the formality and
sophistication of the risk management processes are appropriate
for the risk profile and business plan of the institution.

As part of the strategic planning process, an institution should
perform an analysis of its current and future capital requirements
in relation to its strategic objectives. The strategic plan should
clearly describe the institution’s capital needs in relation to,
among other things, anticipated balance sheet growth and acquisitions,
board approved risk tolerance and access to external capital resources.
Senior management and the board should view capital planning as
a crucial element in institution’s ability to achieve its desired
strategic objectives.

The institution’s board of directors has responsibility for setting
the institution’s tolerance for risk. It should ensure that management:

establishes detailed policies that set institution-wide controls
on the institution’s activities that are consistent with its risk-taking
capacity and appetite

effectively communicates these policies throughout the institution

establishes a framework for assessing the various risks

develops a system to relate risk to the institution’s capital
level as part of its internal assessment of capital adequacy

establishes strong internal controls and a method for monitoring
compliance with internal policies

II. Sound capital assessment and planning

A sound capital assessment process should include the following
elements:

A clear and documented process for evaluating risks and determining
whether or not a risk should result in an explicit amount of capital
being held.Footnote 2

Policies and procedures designed to ensure that the institution
identifies, measures and reports all material risks requiring
capital

A process that relates capital to current and anticipated future
levels of risk in accordance with board approved risk tolerance

A process that states capital adequacy goals with respect to
risk, taking account of the institution’s strategic focus and
business plan

A process of internal controls, reviews and audits to ensure
the integrity of the overall risk management process

Most institutions consider several factors in relating capital
to the level of risk, for example:

A comparison of their own capital levels with regulatory standards
and with those of industry peers

Consideration of identified risk concentrations in credit and
other activities

Their current and desired credit agency ratings, if applicable

Potential severe adverse events, based on historical experiences,
either of the institution itself or the markets in which the institution
conducts business, as well as non-historical scenarios

Planned changes in the institution’s business or strategic
plans, identified changes in its operating environment, and consequential
changes in its risk profile

Institutions with more complex and diverse risk profiles will
also use risk modeling techniques and integrated scenario analyses
to estimate the risks that they may incorporate into their overall
assessment of capital adequacy. Quantifiable estimates of risk used
in this assessment should also have a business use (i.e., should
not be made solely for use in ICAAP) and should be subject to validation.
As economic capital (EC) models were designed as a relative measure
of risk to be used for performance measurement and pricing, the
assumptions underlying these models typically hold under normal
conditions and not under the stressed conditions considered in ICAAP.
Although EC models provide useful inputs to ICAAP, EC is not a substitute
for ICAAP.

In evaluating the adequacy of capital relative to risk and in
making decisions on the appropriate level and structure of capital,
smaller, less complex institutions may continue to rely heavily
on well documented, qualitative considerations. Qualitative considerations
may include implicit or explicit regulatory and market expectations,
peer group analysis, and the results of forward- looking stress
tests and sensitivity analyses of the components of risks that should
be covered by capital. For risks that can not be directly quantified
(e.g., reputational risk), all institutions may use well documented,
qualitative considerations.

An effective capital planning process requires an institution
to assess both the risks to which it is exposed and the risk management
processes in place to manage and mitigate those risks; evaluate
its capital adequacy relative to its risks; and consider the potential
impact on earnings and capital from potential economic downturns.
The institution should identify the time horizon over which it is
assessing capital adequacy. It should evaluate whether long-run
capital targets are consistent with short-run goals, based on current
and planned changes in risk profile and the recognition that accommodating
additional capital needs can require significant lead time. Capital
planning should factor in the potential difficulties of raising
additional capital during downturns or other times of stress.

III. Comprehensive assessment of risks

The ICAAP should address all material risks faced by the institution
as they relate to the adequacy of capital, including all risks explicitly
captured in minimum regulatory capital requirements as well as risks
that are not fully captured under minimum regulatory capital requirements.
The techniques used in assessing material risks should be commensurate
with the scope and complexity of the institution’s risk taking activities.

Credit risk

Institutions should have methodologies that enable them to assess
the credit risk involved in individual exposures and at the portfolio
level. The credit review assessment of capital adequacy should cover
four areas:

Risk rating systems

Portfolio analysis/aggregation

Large exposures and risk concentrations

Securitization and complex structured instruments (where relevant)

The sophistication of the methodologies used to quantify credit
risk should be appropriate to the scope and complexity of the institution’s
credit risk taking activities. Less complex credit risk taking activities
may incorporate a variety of methodologies but should at minimum
take into consideration:

Historical loss experience

Forecast and past economic conditions

Attributes specific to a defined group of borrowers

Other characteristics directly affecting the collectability
of a pool or portfolio of loans

Risk concentrations

The impact of risk concentrations should be reflected in an institution’s
ICAAP. Typical situations in which risk concentrations can arise
include exposures to:

a single counterparty, borrower or group of connected counterparties
or borrowers

industry or economic sectors, including exposures to both regulated
and nonregulated financial institutions such as hedge funds and
private equity firms

geographical regions

similar collateral types or to a single or closely related
credit protection provider, and other exposures arising from credit
risk mitigation techniques

trading exposures/market risk

Risk concentrations can also arise through a combination of exposures
across these broad categories. An institution should have an understanding
of its firm-wide credit risk concentrations resulting from similar
exposures across its different business lines.

An institution may also incur a concentration to a particular
asset type indirectly through investments backed by such assets
(e.g., collateralised debt obligations – CDOs), as well as through
collateral or guarantees used to mitigate credit risk. Institutions
that place more reliance on collateral values than on an evaluation
of a borrower’s or counterparty’s capacity to perform may see themselves
exposed to unexpected market risk in addition to wrong way risk
Footnote 3 , particularly
where the value of the collateral declines.

An institution should have in place adequate, systematic procedures
for identifying high correlation between the creditworthiness of
a protection provider or collateral and the obligors of the underlying
exposures due to their performance being dependent on common factors
beyond systemic risk (i.e. “wrong way risk”).

Risk diversification

Institutions should exercise caution when including risk diversification
benefits in ICAAP. Assumptions on diversification are often based
on expert judgement and are difficult to validate. Institutions
should be conservative in their assessment of diversification benefits,
in particular between different classes of risk, and should consider
whether such benefits exist under stressed conditions.

Securitization

Where securitization activities (e.g., securitization of own-assets
for risk transfer and/or funding; provision of backstop credit facilities
to third-party conduits) are material, an institution’s ICAAP needs
to consider the risks arising from originating, structuring, distributing
and/or investing in such assets, including risks that are fully
captured in minimum regulatory capital requirements. These may include,
for example, reputational risk and the provision of non- contractual
or implicit support to securitization vehicles. Asset performance
may cause assets to return to the balance sheet through amortization
and repurchase. Disruptions in market demand for asset-backed paper
may leave assets in securitization pipelines on the balance sheet
or force the originator to support its own paper. These have adverse
implications for capital and liquidity that should be part of the
institution’s capital and liquidity planning.

An institution should develop prudent contingency plans specifying
how it would respond to capital pressures that arise when access
to securitization markets is reduced. The contingency plans should
also address how the institution would address valuation challenges
for potentially illiquid positions held for sale or for trading.
The risk measures, stress testing results and contingency plans
should be incorporated into the banks risk management processes
and its ICAAP and should result in an appropriate level of capital
under Pillar 2 in excess of the minimum requirements commensurate
with the board’s stated risk tolerance.

Cross border lending

Institutions that engage in cross border lending are subject to
increased risk including country risk, concentration risk, foreign
currency risk (market risk) as well as regulatory, legal, compliance
and operational risks, all of which should be reflected in the ICAAP.
Laws and regulators’ actions in foreign jurisdictions could make
it much more difficult to realize on assets and security in the
event of a default. Where regulatory, legal and compliance risks
associated with concentrations in cross border lending are not considered
elsewhere in an institution’s risk assessment process; additional
capital may be required for this type of lending in an institution's
ICAAP.

Operational risk

Similar rigour should be applied to the management of operational
risk as is done for the management of other significant banking
risks. The failure to properly manage operational risk can result
in a misstatement of the institution’s risk/return profile and expose
the institution to significant losses.

Market risk

Institutions should have methodologies that enable them to assess
and actively manage all material market risks, wherever they arise
throughout the institution (i.e., position, trading desk, business
line or firm-level).

For more sophisticated institutions, the assessment of internal
capital adequacy for market risk, at a minimum, should be based
on both value-at-risk (VaR) or similar modelling and stress testing,
including an assessment of concentration risk and the assessment
of illiquidity under stressful market scenarios.

An institution’s VaR model should be adequate to identify and
measure risks arising from all its trading activities and should
be integrated into the overall internal capital assessment as well
as subject to rigorous ongoing validation. A VaR model’s estimates
should be sensitive to changes in the trading book risk profile.

Interest rate risk in the banking book

The ICAAP should include all material interest rate risk positions
of the institution and consider all relevant repricing and maturity
data. The system should have well-documented assumptions and techniques.
An institution should be able to support its assumptions about the
behavioural characteristics of non-maturity deposits and other assets
and liabilities, especially those exposures characterized by embedded
optionality. Given uncertainty in such assumptions, stress testing
and scenario analysis should be used in the analysis of interest
rate risks.

In general, an increase in uncertainty related to modeling and
business complexity should result in more capital being held.

Liquidity risk

Liquidity is vital to the ongoing viability of any banking organization.
An institution’s capital position can have an effect on its ability
to obtain liquidity, especially in a crisis. Whereas, institutions
are not expected to separately capitalize their liquidity risk,
the stress scenarios for target capital planning and liquidity risk
management should be complementary. Institutions should refer to
OSFI’s Guideline B-6, Liquidity, and the supporting Basel Committee
document Principles
for Sound Liquidity Risk Management and Supervision. Footnote 4

Other risks

Although risks such as strategic and reputation risk are not easily
measurable, institutions are expected to develop techniques for
managing all aspects of these risks. Reputation risk is a key issue
for an industry that relies on the confidence of consumers, creditors
and the general marketplace. For example, when an institution acts
as an advisor, arranges or actively participates in financial transactions,
it may assume insurance, market, credit, and operational risks.
Reputation risk often arises because of inadequate management of
these other risks, whether they are associated with direct or indirect
involvement in the sale or origination of complex financial transactions
or relatively routine operational activities.

Reputational risk can lead to the provision of implicit support,
which may give rise to credit, liquidity, market and legal risk
– all of which can have a negative impact on an institution’s earnings,
liquidity and capital position. An institution should identify potential
sources of reputational risk to which it is exposed. This includes
the institution’s business lines, liabilities, affiliated operations,
off-balance sheet vehicles and markets in which it operates. The
risks that arise should be incorporated into the institution’s risk
management process and appropriately addressed in its ICAAP and
liquidity contingency plans.

Institutions should refer to the industry notice OSFI’s Review of Reputation
Risk Practices: Principles, Observations and Next Steps for
a further discussion of reputation risk.

IV. Stress testing

Stress testing is a risk management technique used to evaluate
the potential effects on an institution’s financial condition, of
a set of specified changes in risk factors, corresponding to exceptional
but plausible eventsFootnote 5 . An institution’s
capital planning process should incorporate rigorous, forward-looking
stress testing that identifies possible events or changes in market
conditions that could adversely impact the institutions. In their
ICAAPs, institutions should examine future capital resources and
capital requirements under adverse scenarios. The results of forward-looking
stress testing should be considered when evaluating the adequacy
of an institution’s capital.

V. Monitoring and reporting

The institution should establish an adequate system for monitoring
and reporting risk exposures and assessing how changes to the institution’s
risk profile affects the need for capital. The institution’s senior
management and board of directors should receive regular reports
on the institution’s risk profile and capital needs. These reports
should allow senior management to:

Evaluate the level and trend of material risks and their effect
on capital levels

Evaluate the sensitivity and reasonableness of assumptions
used in the capital assessment measurement system

Determine that the institution holds sufficient capital against
the various risks and is in compliance with established capital
adequacy goals

Assess the future capital requirements based on the institution’s
reported risk profile and make necessary adjustments to the institution’s
strategic plan accordingly

VI. Internal control review

The institution’s internal control structure is essential to the
capital assessment process. Effective control of the capital assessment
process includes an independent review and, where appropriate, the
involvement of internal and external audits. The institution’s board
of directors has a responsibility to ensure that management establishes
a system for assessing the various risks, develops a system to relate
risk to the institution’s capital level, and establishes a method
for monitoring compliance with internal policies. The board should
regularly verify whether its system of internal controls is adequate
to ensure the well-ordered and prudent conduct of business.

The institution should conduct periodic reviews of its risk management
process to ensure its integrity, accuracy, and reasonableness. Areas
that should be reviewed include:

Appropriateness of the institution’s capital assessment process,
given the nature, scope and complexity of its activities

Identification of large exposures and risk concentrations

Accuracy and completeness of data inputs into the institution’s
assessment process

Reasonableness and validity of scenarios used in the assessment
process

Stress testing and analysis of assumptions and inputs

Interaction of ICAAP with Supervisory Review

OSFI assesses capital adequacy at two levels. An institution must
have sufficient capital to meet its target regulatory requirements
(regulatory capital), as well as sufficient capital to support its
risk profile, (i.e., its Inherent Risks and Overall Net Risk (ONR)) as determined
through the OSFI
Supervisory Framework. Footnote 6

OSFI’s risk assessment process begins with an evaluation of the
inherent risk within each significant activity of a financial institution.
OSFI then examines the quality of risk management applied to mitigate
these risks. Considering this information, OSFI arrives at an assessment
of both the level of net risk of the significant activity and the
direction of the net risk, i.e., whether it is decreasing, stable
or increasing. Then, taking into account the materiality of each
of the significant activities of a company, OSFI arrives at an overall
net risk rating and its direction.

OSFI then develops a composite risk rating (and direction) for
the financial institution, taking into account both our assessment
of the overall net risk (which includes an assessment of the adequacy
of risk management processes) and our assessment of financial factors,
such as capital and earnings. Capital can be assessed as “strong”,
“acceptable”, “needs improvement” or “weak”.

The depth and frequency of supervisory review of an institution’s
ICAAP will be proportional to the nature, scale and complexity of
its activities, and the risks posed to OSFI’s supervisory objectives
with respect to the safety and soundness of the institution.

The dialogue between, on the one hand, OSFI’s assessment of inherent
risk and ONR, and the institutions’ ICAAP on the other, will embrace
the following four elements:

Element 1: The level of conservatism in internal estimates
of the risks captured in the CAR guideline A and A-2 (credit,
market, and operational risk)

Element 2: Material risks not fully captured under CAR A and
A-1 (for example, concentration risk, the degree of conservatism
of estimates used by institutions approved for advanced approaches
under CAR A-1)

Element 4: External factors, where not already considered in
the previous points, including stress testing in Internal Ratings
Based Approaches, impact of economic cycles and other external
risks and factors

OSFI expects that capital assessment will not become a formula-driven
process of add-ons. Expert judgement will continue to be necessary
to operationalize the assessment and quantification of risk and
integrate those results into the overall assessment of capital.
Initially, this assessment will likely include measures of outliers
for risk concentrations and outliers for interest rate risk in the
banking book.

Once capital rating criteria are more fully developed and experience
is gained from a reasonable period of implementation, the supervisory
assessment of the internal target capital for some institutions
could indicate that the industry-wide target is conservative for
that institution or not conservative enough. This would lead to
discussions with the institution about a more appropriate level
of capital within the target capital framework.

- END -

Footnotes

Footnote 1

International Convergence of Capital Measurement and Capital
Standards: a Revised Framework, issued by the Basel Committee
on Banking Supervision, June 2006

Not all risks can be directly quantified and capitalized. Material
risks, including those that are difficult to quantify in an
ICAAP framework, should be mitigated by internal controls and
contingency plans.

Wrong way risk is defined in the CAR Guideline, refer to
Chapter 3, Annex 4, Section 1, Definitions and Terminology:

General Wrong-Way Risk arises when the
probability of default of counterparties is positively correlated
with general market risk factors.

Specific Wrong-Way Risk arises when the
exposure to a particular counterpart is positively correlated
with the probability of default of the counterparty due
to the nature of the transactions with the counterparty.